Comtrade Distribution d.o.o. Beograd Mobile Privacy Policy
Effective Date: 2023/09/01
Updated: 2023/09/01
COMTRADE DISTRIBUTION
D.O.O. BEOGRAD and subsidiaries (“we”, “us”, “our”, “COMTRADE DISTRIBUTION D.O.O. BEOGRAD”) are
committed to protecting your privacy. This Privacy Policy (“Policy”) describes
our practices in connection with information privacy on Personal Data we
process through your individual use of the following services, products, and
related mobile applications (collectively, the “Products”):
·TESLA SMART THINGS Mobile Application
In this Privacy Policy, “Personal Data” means
information that can be used to identify an individual, either from that
information alone, or from that information and other information we have access
to about that individual. “Smart Devices” refers to those nonstandard computing
devices produced or manufactured by hardware manufacturers, with human-machine
interface and the ability to transmit data that connect wirelessly to a
network, including: smart home appliances, smart wearable devices, smart air
cleaning devices, etc. “Apps” refers to those mobile applications developed by COMTRADE DISTRIBUTION D.O.O. BEOGRAD that provide end users remote control to Smart Devices and with
the ability to connect to the supplier IoT Platform.
For other branded mobile applications powered by
COMTRADE DISTRIBUTION D.O.O. BEOGRAD, our
Clients control all the Personal Data collected through our Products. We
collect the information under the direction of our Clients and the processing
of such information shall be limited to the purpose of providing the service
for which our Clients has engaged us. If you are a customer of one of our
Clients and would no longer like to be contacted by one of our Clients that use
our service, please contact the Client that you interact with directly.
What Personal Data do we
collect
In order to provide our services to you, we will
ask you to provide necessary Personal Data that is required to provide those
services. If you do not provide your Personal Data, we may not be able to
provide you with our products or services.
1.Information You Voluntarily
Provide Us
·Account or Profile Data: When you register an account with us, we may collect your name
and contact details, such as your email address, phone number, user name, and
login credentials. During your interaction with our Products, we may further
collect your nickname, profile picture, country code, language preference or
time zone information into your account.
- Feedback: When
using feedback and suggestion features in our Products, we will collect
your email address, mobile phone number and your feedback content to
address your problems and solve device failures on a timely basis.
2.Information We Collect Atomitically
·Device Information: When you interact with our Product, we Atomitically collect
device information, such as the MAC address of your devices, IP address,
wireless connectioninformation, operating system type and version,
application version number, push notification identifier, log files, and mobile
network information.
·Usage Data: During your interaction with our Sites and Services, we Atomitically
collect usage data relating to visits, clicks, downloads, messages
sent/received, and other usage of our Sites and Services.
·Log Information: When you use our app, the system and exception log may be
uploaded.
·Location Information: We may collect information about your real-time precise or
non-precise geo-location when you use our specific Products or Services,.
3.Smart Devices Related Information:
·Basic Information of Smart
Devices: When you connect your Smart Devices with our Products or
Services, we may collect basic information about your Smart Devices such as
device name, device ID, online status, activation time, firmware version, and
upgrade information.
·Information Reported by
Smart Devices: Depending on the different Smart Devices you
elect to connect with our Products or Services, we may collect different
information reported by your Smart Devices..
Purposes and legal basis
for processing Personal Data
The
purpose for which we may process information about you are as follows:
- Provide
You Services: We process your account and
profile data, device information, usage data, location information, and
Smart Device related information to provide you with our Products and
Services that you have requested or purchased. The legal basis for this
processing is to perform our contract with you according to
our Terms of Use.,
- Improve
Our Services: We process your device information,
usage data, location information and Smart Device related information to
ensure the functions and safety of our Products, to develop and improve
our Products and Services, to analyze the efficiency of our operations,
and to prevent and trace fraudulent or inappropriate usage. The legal basis for this processing is to perform our contract
with you according to our Terms of Use.
·Non-marketing Communication: We process your Personal Data to send you important
information regarding the Services, changes to our terms, conditions, and
policies and/or other administrative information. Because this information may
be important, you may not opt-out of receiving such communications. The legal
basis for this processing is to perform our contract with you according
to our Terms of Use.
- Marketing
Communication: We may process your Personal
Data to provide marketing and promotional materials to you on our Products
and Services. If we do so, each communication we
send you will contain instructions permitting you to opt-out of receiving
future communications of that nature.The legal basis for this processing is your consent.
Additionally,
if you consent to participate in our lottery, contest or other promotions,
we may use your Personal Data to manage such activities.
- Personalization:
We may process your account and profile data, usage data, device
information to personalize product design and to provide you with services
tailored for you, such as recommending and displaying information and
advertisements regarding products suited to you, and to invite you to
participate in surveys relating to your use of our Products. The legal
basis for this processing is your consent.
- Legal
Compliance: We may process your Personal
Data as we believe to be necessary or appropriate: (a) to comply with
applicable laws and regulations; (b) to comply with legal process; (c) to
respond to requests from public and government authorities (d) to enforce
our terms and conditions; (e) to protect our operations, business and
systems; (f) to protect our rights, privacy, safety or property, and/or
that of other users, including you; and (g) to allow us to pursue
available remedies or limit the damages that we may sustain.
Who do we share Personal
Data with?
At COMTRADE DISTRIBUTION D.O.O. BEOGRAD, we only share Personal Data in ways that we tell you about. We
may share your Personal Data with the following recipients:
- To
our third-party service providers who perform certain business-related
functions for us, such as website hosting, data analysis, payment and
credit card processing, infrastructure provision, IT services, customer
support service, e-mail delivery services, and other similar services to
enable them to provide services to us.
- To
our customers and other business partners who provide you, directly or
indirectly, with your Smart Devices, and/or networks and systems through
which you access and use our Sites and Services.
- To
an affiliate or other third party in the event of any reorganization,
merger, sale, joint venture, assignment, transfer or other disposition of
all or any portion of our business, assets or stock (including without
limitation in connection with any bankruptcy or similar proceedings). In
such an event, you will be notified via email and/or a prominent notice on
our website of any change in ownership, incompatible new uses of your
Personal Data, and choices you may have regarding your Personal Data.
- As
we believe to be necessary or appropriate: (a) to comply with applicable
laws and regulations; (b) to comply with legal process; (c) to respond to
requests from public and government authorities, including public and
government authorities outside your country of residence; (d) to enforce
our terms and conditions; (e) to protect our operations, business and
systems; (f) to protect our rights, privacy, safety or property, and/or
that of other users, including you; and (g) to allow us to pursue
available remedies or limit the damages that we may sustain.
- To
subsidiaries or affiliates within our corporate family, to carry out
regular business activities.
Except for the third parties described above, to
third parties only with your consent.
International Transfer of
Information Collected
To facilitate our operation, we may transfer,
store and process your Personal Data in jurisdictions other than where you
live. Laws in these countries may differ from the laws applicable to your
country of residence.
Your Rights Relating to
Your Personal Data
We
respect your rights and control over your Personal Data. You may exercise any of
the following rights:
Via the “Profile – Personal Center” in our Products
You do not have to pay a fee and we will aim to respond you
within 30 days. If you decide to email us, in your request, please make clear
what information you would like to have changed, whether you would like to have
your Personal Data deleted from our database or otherwise let us know what
limitations you would like to put on our use of your Personal Data. Please note
that we may ask you to verify your identity before taking further action on
your request, for security purposes.
You
may:
·Request access to the Personal Data
that we process about you;
·Request that we correct inaccurate or
incomplete Personal Data about you;
·Request deletion of Personal Data about
you;
·Request restrictions, temporarily or
permanently, on our processing of some or all Personal Data about you;
·Request transfer of Personal Data to
you or a third party where we process the data based on your consent or a
contract with you, and where our processing is Atomited; and
·Opt-out or object to our use of
Personal Data about you where our use is based on your consent or our
legitimate interests.
Security
We
use commercially reasonable physical, administrative, and technical safeguards
to preserve the integrity and security of your Personal Data. COMTRADE DISTRIBUTION D.O.O. BEOGRAD provides
various security strategies to effectively ensure data security of user and
device. As for device access, COMTRADE
DISTRIBUTION D.O.O. BEOGRAD proprietary algorithms are employed to
ensure data isolation, access authentication, applying for authorization. As
for data communication, communication using security algorithms and
transmission encryption protocols and commercial
level information encryption transmission based on dynamic keys are
supported. As for data processing, strict data filtering and validation and
complete data audit are applied. As for data storage, all confidential
information of users will be safely encrypted for storage. If you have reason
to believe that your interaction with us is no longer secure (for example, if
you feel that the security of any account you might have with us has been
compromised), you could immediately notify us of the problem by emailing TESLA SMART THINGS.MZ@gmail.com
Data Retention
We
process your Personal Data for the minimum period necessary for the purposes
set out in this Privacy Policy, unless there is a specific legal requirement
for us to keep the data for a longer retention period. We determine the
appropriate retention period based on the amount, nature, and sensitivity of
your Personal Data, and after the retention period ends, we will destruct your
Personal Data. When we are unable to do so for technical reasons, we will
ensure that appropriate measures are put in place to prevent any further such
use of your Personal Data.
Changes to this Privacy Policy
We may update this Privacy Policy to
reflect changes to our information practices. If we make any material changes
we will notify you by email (send to the e-mail address specified in your
account) or by means of a notice in the mobile applications prior to the change
becoming effective. We encourage you to periodically review this page for the
latest information on our privacy practices.
Contact
Us
If you have any questions about our
practices or this Privacy Policy, please contact us as follows:
- COMTRADE DISTRIBUTION D.O.O. BEOGRAD
.Email: appdevelopment@tesla.info